International Taxation III – Advanced International Tax Issues (Seminar)

Mr. Flanagan and Mr. Patton

This course will be of interest to those students who have decided that they likely will practice in the field of international taxation or who have a strong intellectual interest in this subject matter. The course will address in considerable detail a number of advanced and highly technical subjects, including: international acquisitions; review of rules applicable to reorganizations and particularly the application of section 367(a); the use of section 338 in international transactions; an overview of transfer pricing rules in regulations under section 482, with emphasis on pricing for services and intangibles; international tax issues associated with intangibles, including ownership of IP, licensing arrangements, qualified cost-sharing arrangements, and section 367(d); advanced use of hybrid entities in international structures; section 304 and its implication in international transactions; and section 367(b), emphasizing the surprising rules that are designed to close the back door to avoiding taxation of foreign E&P for CFCs. Depending on time other subjects or significant regulatory developments may be addressed.

Prerequisites: International Tax I and International Tax II. Notes: Limited Enrollment. Grade based on a written paper of approximately 25 pages on a topic related to the course as agreed with the professors.